Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Reopening of assessment was challenged because the stated grounds-an alleged clerical mistake in inventory computations and unexplained cash deposits-no longer survive: the inventory-based addition has since been deleted by the ITAT and the Revenue does not dispute that deletion, and the cash deposits were specifically queried and satisfactorily explained with the cash book produced during original scrutiny, leading the AO then to make no addition. The article concludes that reassessment here amounts to a mere change of opinion and is therefore not justified.
Reopening of assessment was challenged because the stated grounds-an alleged clerical mistake in inventory computations and unexplained cash deposits-no longer survive: the inventory-based addition has since been deleted by the ITAT and the Revenue does not dispute that deletion, and the cash deposits were specifically queried and satisfactorily explained with the cash book produced during original scrutiny, leading the AO then to make no addition. The article concludes that reassessment here amounts to a mere change of opinion and is therefore not justified.
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